Webinar | Taxpayer Debt: Insights from Recent Case Law - CPD Consortium

Taxpayer Debt:

Insights from Recent Case Law

The recent case, Henque 3935 CC t/a PQ Clothing Outlet v Commissioner for the South African Revenue Service, decided in the Supreme Court of Appeal on 12 May 2025, provides critical insights into tax debts owed to SARS.

This case, decided in favour of the taxpayer, raised essential questions regarding whether tax liability arising from an additional assessment raised by Commissioner for South African Revenue Service (SARS) after commencement of business rescue is a pre- or post-commencement debt, and whether such liability may be set off against a VAT credit which became due to the company by SARS after the company was placed in business rescue. In addition to this the webinar will further expand on further case law such as Wiesse and JBSA cases.

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Date:

21 October 2025

Time:

10:00 - 11:00

Platform:

Zoom

Cost:

R180.00

CPD Points:

1.0

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Join this essential session to gain clarity on the legislative framework, recent case law, and the practical implications of tax debts during business rescue.  

Key topics

In this session, the following key topics will be discussed: 

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  • Overview of the legislative framework
  • Recent caselaw including:
    - Henque 3935 CC t/a PQ Clothing Outlet v CSARS
    - JBSA Props (Pty) Ltd and Another v Commissioner for South African Revenue Services and Others
    - Christoffel Hendrik Wiese and Others v CSARS
  • Practical Considerations
  • Q&A
  • 00Days
  • 00Hours
  • 00Minutes
  • 00Seconds

Who Should Join?

Tax Practitioners
& Advisors

Guiding clients through SARS disputes, assessments, and credits during business rescue.

Corporate Tax Specialists
& Accountants

Managing VAT credits, set-offs, and tax exposures in distressed companies.

Business Rescue Practitioners
& Legal Advisors

Navigating business rescue and tax debts

Financial Managers
& Directors

Overseeing company obligations.

Meet The Speakers

Prof Carika Keulder

Professor of Law | Taxation Specialist

Prof Carika Keulder holds the degrees LLB, LLM, LLD from the University of Pretoria and is an admitted attorney and notary public.

She is an associate professor at the Law School of the University of Witwatersrand and lectures taxation on undergraduate and postgraduate level.

She frequently presents research papers, locally and abroad, and has published several articles in peer-reviewed accredited journals.

Her research focus is tax administration and taxpayers’ rights, and she holds a C2-rating from the National Research Foundation.

 

Junaid Bhayla

Tax Attorney

Junaid Bhayla is an admitted attorney of the High Court of South Africa, with several years of legal experience under his belt.

He has vast experience in both civil and criminal litigation, as well as consulting experience in tax affairs pertaining to SARS engagement – specifically matters of tax debt and crypto tax compliance.

Junaid has pivoted from formal legal practice to the consulting industry, and now navigates SARS engagement, compliance, and the various aspects that accompany this field of law.

Join this essential session to gain clarity on the legislative framework, recent case law, and the practical implications of tax debts during business rescue. 

#BusinessRescue #SARSCompliance #TaxDisputes #VATCredits #TaxLawSA#TaxPractitioners #CPDConsortium 

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What Our Clients are Saying

Thanks to the speakers. Thoroughly informative and enjoyable. I look forward to the Q& A to follow..
- Past IT3(t) Reporting Attendee
Thank you for this webinar, it was well informed an excellently prepared. Looking forward to the next one!
- Past IT3(t) Reporting Attendee
The speakers are the most passionate educators. They make it easy to learn and follow. I enjoy all of the CPD Sessions
and always feel that I learn a lot from them
- Past IT3(t) Reporting Attendee
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Terms & Conditions 2025

What does an annual subscription cover?

In accordance with the SARS External Guide: Criteria for the Registration of Tax Practitioners (effective 11 October 2024) at page 5, “a year commences on 1 January and ends on 31 December of a year…”

Therefore the 2025 annual package applies to the year ended 31 December 2025.  CPD Consortium acknowledges that the compliance requirements of the relevant RCB’s extend beyond the calendar year and therefore subscription package holders will enjoy access to the following until 31 October 2026:

  • CPD Consortium Portal, to view and download certificates of completion
  • All 2025 on demand offerings

Renewing your subscription for the 2026 year provides full access to on demand offerings and live events from 1 January 2026. 

Note: It is essential to understand the requirements of your RCB in respect of cut-off dates and reporting requirements.

What are the SARS CPE (CPD) requirements?

SARS External Guide: Criteria for the Registration of Tax Practitioners at page 5:

  • A tax practitioner must have successfully completed a minimum of 18 verifiable CPE hours per year, which consists of 10 tax hours, 2 ethics hours, and 6 hours relating to the service provided.
  • A tax practitioner is required to retain a record of their CPE for 5 years, e.g., competency certificates

Please note: A year commences on 1 January and ends on 31 December of a year, and therefore the 18 hours is calculated on a pro rata basis for newly registered tax practitioners depending on the registration date.

Note: It is essential that a tax practitioner ensures that any additional requirements of their RCB are also met.

All webinars, learning materials, slides, and Q&A answers are for training purposes, do not constitute tax advice or options and should not be construed as such. 

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  • “CPD Consortium (Pty) Ltd” / “we” / “our” refers to CPD Consortium (Pty) Ltd and its affiliates. 
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2. Packages

  • CPD Consortium (Pty) Ltd offers Annual Packages. 
  • Subscription access includes: 
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  • Package inclusions may vary each year. Full details are provided on our website. 
  • Packages are valid for the calendar year (1 January – 31 December), in accordance with the SARS CPE (CPD) year.1 

Access to CPD Portal 

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Upon expiry of the annual package: 

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  • Access to on demand offerings for non-renewing subscribers will remain available until 31 October of the following year, after which access will be terminated. 
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  • After termination, CPD Consortium (Pty) Ltd will continue to securely store records of certificates for a period of 5 years, which can be requested in writing. 

3. Payment Terms

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4. Cancellations & Refunds

  • Refunds for live events / webinars: If an attendee is unable to attend a live event, the recording will be made available to them.  If their recording is not available for any reason, a full refund will be processed, on provision of the relevant supporting documentation. 
  • Package purchases are refundable to the extent that no events have been attended and within 5 days of the subscription date. CPD Consortium (Pty) Ltd reserves the right to cancel or reschedule events. In such cases, clients may attend the rescheduled event, access the recording, or request a refund. 

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  • You are granted a non-exclusive, non-transferable licence to use materials for personal CPD purposes. 

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  • CPD Consortium (Pty) Ltd will make every effort to deliver services as advertised, but reserves the right to make changes to speakers, content, or schedules. 
  • We are not liable for indirect or consequential losses, including loss of income or opportunity. 
  • Technical disruptions outside our control (e.g. internet outages, load-shedding) do not qualify for refunds, but recordings will be provided where possible. 
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 9. Governing Law

  • These T&Cs are governed by the laws of South Africa. 
  • Disputes shall fall under the jurisdiction of South African courts. 
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Professor Deborah Tickle

FROM THE DAVIS TAX COMMITEE
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Keitumetse Sesana

TAX TECHNICAL SPECIALIST AT SAIT

Keitumetse Sesana is a registered SARS practitioner who also holds the designation of Master Tax Practitioner from the South African Institute of Taxation. With a solid background in international corporate tax matters from her previous roles at KPMG South Africa, she contributes important insights to the development of tax policy across various areas.  

As a Tax Technical Specialist, Keitumetse currently specialises in tax legislative policy engagement across the various areas of taxation and also manages stakeholder relations and facilitates engagement with key government departments. She leads and is responsible for the strategic oversight and positioning of the SAIT Tax Technical workgroups, as well as other strategic engagements related to legislation. Her collaborative efforts and strategic engagement with the various industry tax specialists that are members of the SAIT Tax Technical workgroups is vital for drafting and submitting proposals to entities such as the Parliament of South Africa, National Treasury, SARS, the Department of Trade, Industry and Competition and the Office of the Tax Ombud with the aim of influencing and shaping the tax legislative framework. 

In addition to her legislative work, Keitumetse curates and manages content for tax practitioners as part of their Continuous Professional Development requirements. This includes hosting webinars and drafting content for various SAIT publications, helping professionals stay informed in the evolving tax landscape. 

Keitumetse holds a Master of Laws (LLM) specialising in Tax Law, a Bachelor of Laws (LLB), and a Bachelor of Commerce (BCom) Law degree. Keitumetse is passionate about contributing to and transforming the tax legislative landscape. 

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Delano Abdoll

Admitted Attorney, BA (Law), LLB, LLM at Tax Consulting SA

Delano is a highly skilled attorney admitted to the High Court of South Africa, with extensive knowledge and expertise in tax law. He holds a Bachelor of Arts in Law, a Bachelor of Laws, and a Master of Laws degree in Procedural Law, all obtained from the University of Pretoria. Delano has a strong focus on expatriate tax and individual cross-border taxation, making him an expert in dealing with complex tax issues faced by individuals who work or reside across international borders. With his comprehensive understanding of tax laws and regulations, he is able to provide exceptional advice and support to clients in need of expert tax planning and management.

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Tertius du Plessis

Professional Accountant and Crypto Taxpert

Tertius is a seasoned expert in the fields of finance and taxation, with a specialised focus on the realm of cryptocurrencies. His portfolio includes accounting services for a diverse range of clients, including individuals, private companies (Pty) Ltd’s, trusts, and deceased estates. He boasts a Bachelor of Accounting (BAcc) degree and has spent eight enriching years in the blockchain/cryptocurrency sector. In his role as a CryptoTaxpert, Tertius skillfully navigates clients through the intricacies of transitioning between fiat currency and cryptocurrency. His extensive knowledge of cryptocurrency, blockchain technology, trading, and HODLing, positions him as a reliable interpreter and manager of crypto data. Tertius’ profound understanding of South African cryptocurrency tax regulations equips him to deliver SARS-compliant, optimised crypto tax reports. He is dedicated to helping clients manage their crypto assets and ensuring a seamless flow of funds. He lives by the philosophy, “My compensation is not for the hours I put in, but for the value I deliver in those hours.” He believes that “What you pay is the price, what you gain is the value.” As a #CryptoTaxpert, his mission is to deliver unparalleled value to his clients.

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Piet Nel

CA (SA) Specialising in taxation

Piet Nel is a CA (SA) who specializes in taxation. He was previously the Project Director of professional development (tax) at SAICA, and the project director for tax at SAICA.  Before joining SAICA again, he was involved in tax consulting and tax dispute resolution. 

He is an accounting member of the Tax Court, second term. He is a visiting adjunct professor at Wits and was previously a lecturer in tax at the University of Pretoria to students doing a Master’s degree and at UNISA at postgraduate level.

He was a member of SAICA’s national tax committee and is still quite active in the development of tax legislation in South Africa by commenting on proposed legislation. Over a period of more than three decades, he presented numerous tax seminars and workshops to tax practitioners.

He regularly speaks on radio and TV and publishes tax related articles.He is involved, as a member of the SAICA’s Examination Committee, in setting the examination to test initial competence for prospective CA (SAs).

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Sophia Steyn

Admitted Attorney and legal advisor

Sophia Steyn is an experienced attorney with a strong background in will drafting, trust administration, and estate administration. With ten years of legal practice experience, including owning and managing her own practice, Sophia brings valuable management skills and a client-focused approach to her work. Currently employed at Rauch Gertenbach Inc., she specialises in drafting wills, establishing trusts, administering estates. Sophia’s expertise, professionalism, and commitment to exceptional client service make her a trusted legal practitioner in her field.

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Jerry Botha

Managing Partner
at Tax Consulting SA

Jerry Botha commenced his tax career in United Kingdom / United States Tax and served articles at McCorkindale & Holton’s London office. After being with the Big-4 accounting firms, in 2005 he started his own niche tax practice.

Tax Consulting South Africa has grown over the years to the largest independent tax practice in South Africa, which specialises in the most complex areas of tax planning and compliance. The firm is SARS recognised as a top 6 tax practice and a leading advisor to large multinational corporates, globally mobile individuals, high net worth professionals and families; but also fellow professionals on complex areas of South African and international tax.

Tax Consulting South Africa authored LexisNexis’ “Expatriate Tax” textbook, as critically acclaimed by the esteemed Judge Dennis Davis. The textbook is now in its 2nd edition.

Jerry enjoys a collaborative approach with fellow professionals, continuous professional development, commenting on legal development and growing the next generation of professionals.

 

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Catherine Fourie

HEAD OF CPD CONSORTIUM

Catherine is a Chartered Accountant (CA(SA)) and tax practitioner who completed her articles at Deloitte in 2003. After three secondments to the United States of America and Canada, she rejoined Deloitte as audit manager for four years, whereafter she has been a lecturer on the BCom Accounting programme with the Nelson Mandela University for 15 years until early 2024. Her main subjects were Taxation, Auditing and Ethics and Corporate Governance, as well as lecturing on the MCom (Taxation) program. She has a deep passion for teaching to which she has dedicated most of her professional career, especially fundamental principles. She implemented innovative learning and teaching practices, both online and hybrid/flexible; always ensuring impactful learning. As a member of the SAICA Digital Acumen Working Group she has always been passionate about innovation and resilience, which are both essential for the sustainability and growth of the modern professional. With the many students which have been through her lectures, she is excited to now bring digital innovation to the upskilling of professionals who work in the ever-changing landscape of tax and accounting. Her approach and style is one of ensuring a sound technical base, from where she quickly makes tax and accounting highly practical and relevant; delivering immediate value for anyone attending her training sessions.

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Sidney Fletcher

Senior Manager of Trust and Deceased Estate Compliance at Tax Consulting SA

Sidney is a versatile and results-driven qualified Senior Tax Practitioner. He has more than 20 years of experience working for SARS and was responsible for Taxpayer Education for a big part of that period. He is a dedicated professional with extensive knowledge and his affinity for Individual Taxes makes him an excellent tax planner and skilled at tax optimisation. Committed to the best care for clients through transparent communication. Skilled in negotiation with a strong ability to problem solve to assist clients with tax problems.

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Roxshanna du Toit

Independent Trust and Fiduciary Services Expert & CPD Project Coordinator

Roxshanna is a seasoned tax professional and was until February 2024 the Head of Tax, Standard Trust Limited. As one of the market’s largest leading fiduciary services providers, she worked daily on complex matters pertaining to tax and accounting for trusts, deceased estates and the commercial and family interests which necessarily comes therewith. She has a BCom (Taxation Honours) and also served as a lead representative for the Banking Association of South Africa (BASA) in providing input to SARS directly as impacts the fiduciary arena. Her interest sphere is streamlined solutions to overcome the administrative and operational challenges of trustees, accountants, tax practitioners and executors. She considers herself as a practical generalist who excels in getting the job done, and she has been involved in untangling, resolving and ensuring compliance of some of the largest and most complex South African and international trusts, estates and family structures. Her decision to start her own practice allows her to expand her professional horizon as well as spend more quality time with her son.